Stop Food Irradiation Project HOME January 27, 2001 FOOD IRRADIATION LIMIT IN DANGER OF BEING REMOVED In March, the Codex Committee on Food Additives and Contaminants (CCFAC) will meet in The Hague to consider a proposal to remove the maximum dose for irradiated food - - currently set at 10 kiloGray (the equivalent of 330 million chest x-rays). For many reasons, this is a rash and ill-advised proposal: (1) The International Consultative Group on Food Irradiation (ICGFI), the organization that advises the CCFAC on global food irradiation policy, ignored its own recommendation to study the potential toxicity of high-dose irradiated food before voting at a closed-door meeting in Geneva last November to endorse removing the maximum dose. (2) ICGFI has ignored a 1998 study - - which the group helped finance - - revealing that a chemical formed in irradiated food containing fat is "clearly" toxic and "clearly" mutagenic. (3) Many serious questions raised by a WHO researcher in 1969 regarding the potential toxicity, carcinogenicity and mutagenicity of irradiated food - - a researcher who feared a thalidomide-type disaster - - have yet to be sufficiently answered. (4) High-dose irradiation destroys vitamins and other nutrients, frequently to a significant degree. Tell the CCFAC not to adopt the Proposed Draft Revision to the Codex General Standard for Irradiated Foods until these and other unresolved concerns related to the safety and wholesomeness of irradiated food are satisfactorily addressed. (For more background on this issue, see http://www.citizen.org/press/pr-cmep87.htm) DEADLINE FOR COMMENTS IS 15 FEBRUARY. Reference Agenda Item 9a, CX/FAC 01/11 in your comments. (See sample below.) Send your comments to: S.P.J. Hagenstein Ministry of Agriculture Nature Management and Fisheries P.O. Box 20401 2500 EK, The Hague The Netherlands E-mail: s.p.j.hagenstein@vvm.agro.nl Also, send a copy to: The Secretary Codex Alimentarius Commission Joint FAO/WHO Food Standards Programme Viale delle Terme di Caracalla 00100 Rome Italy E-mail: Codex@fao.org SAMPLE COMMENTS Ms. Hagenstein: On behalf of our membership, I strongly urge the Codex Committee on Food Additives and Contaminants to reject the Proposed Draft Revision to the Codex General Standard for Irradiated Foods until numerous unresolved concerns related to the safety and wholesomeness of irradiated food are satisfactorily addressed. The Proposed Draft Revision is listed as Agenda Item 9a (CX/FAC 01/11) for the CCFAC meeting scheduled for 12-16 March 2001 in The Hague. For many reasons, this is an ill-advised proposal: (1) The International Consultative Group on Food Irradiation ignored its own 1994 recommendation to study the potential toxicity of high-dose irradiated food ("Report of a Consultation," WHO, 1995) before deciding 1-3 November 2000 at its 17th annual meeting in Geneva to endorse amending the Codex General Standard for Irradiated Foods by removing the current 10 kiloGray dose limit. (2) A recent study - - funded in part by ICGFI - - revealed that a chemical called 2-DCB, which is formed in irradiated food containing fat, is "clearly" toxic and "clearly" mutagenic (Delincee, H. and Pool-Zobel, B. "Genotoxic Properties of 2-Dodecylcyclobutanone, a Compound Formed on Irradiation of Food Containing Fat," Radiation Physics and Chemistry, 52:39-42, 1998). (3) Many serious questions raised by a WHO researcher in 1969 regarding the potential toxicity, carcinogenicity and mutagenicity of irradiated food - - a researcher who feared a thalidomide-type disaster - - have yet to be sufficiently answered (Schubert, J. "Mutagenicity and Cytotoxicity of Irradiated Foods and Food Components," Bulletin of the World Health Organization, 41:873-893). (4) High-dose irradiation destroys vitamins and other nutrients, frequently to a significant degree ("High-Dose Irradiation," WHO, 1999). Approving the Proposed Draft Revision would be irresponsible, in the face of vast uncertainty as to the safety wholesomeness of irradiated food, and in the face of evidence suggesting that irradiated food may not be safe for human consumption. I urge you to reject this proposal. Respectfully,